The Presumption of Innocence Podcast: Episode 45 - The Grit, Grace and Gift of Second Chances
Wicked Coin: The "Fat Leonard" Scandal
Navigating Civil Standing Requirements for Defense Success — RICO Report Podcast
Episode 330 – Halyna Senyk on Anti-Corruption Progress in Ukraine
Managing Corruption Risk in Latin America
The Presumption of Innocence Podcast: Episode 38 - A Blueprint for Compliance: The Fraud Pentagon Theory
Episode 323 - Carlos Villagran Discusses Rebuilding a Corporate Culture After a Crisis
The Presumption of Innocence Podcast: Episode 34 - A Conversation With Jesse Eisinger, Author of 'The Chickenshit Club: Why the Justice Department Fails to Prosecute Executives'
Episode 317 -- A Deep Dive into the Trafigura FCPA Settlement
What's Going on with FCPA?
Episode 316 -- DOJ Announces New Whistleblower Policy
RICO Vicarious Liability — RICO Report Podcast
Episode 313 -- The Coming Criminal Corporate Sanctions Enforcement Storm
RICO Damages — RICO Report Podcast
Corruption, Crime & Compliance: DOJ’s Shifting Approach to Recidivism and Self-Disclosure
Episode 305 -- Deep Dive into SAP FCPA Settlement
AGG Talks: Antitrust and White-Collar Crime Roundup - Developments in the Trump Indictments and Recent Supreme Court Issues
Episode 300 -- Deep Dive into DOJ FCPA Settlement with Two U.K. Reinsurance Companies for Bribery in Ecuador
AGG Talks: Antitrust and White-Collar Crime Roundup - Examining the Latest Updates in the Pending Criminal and Civil Litigation Against Trump
The EU Directive for Combatting Corruption
Leveraging 40,000 anonymous ethics hotline reports and expansive customer interviews, Syntrio’s latest analysis uncovers trends in misconduct, reporting, and more...more
If there ever is an example of a rotten corporate culture, Wells Fargo sits at the head of the class. Since Wells Fargo’s sales pressure scandal, Wells Fargo has continued to suffer from a string of scandals and misconduct. ...more
Are you looking to better… - Support, enhance, and manage a compliance and ethics program? - Mitigate risk within your organization? - Understand the components of effective program infrastructure? SCCE’s Basic...more
Today, I continue a multi-part exploration of one world’s largest anti-corruption enforcement actions, the J&F Investimentos SA (J&F) matter. It involved huge fines and penalties in both Brazil and the United States. Of...more
Companies should identify and, where appropriate, manage risk associated with gifts and entertainment by incorporating a clear policy into their overall corporate compliance strategy. On September 11, 2020, the French...more
I did not think that the Wells Fargo fraudulent accounts scandal could get worse for the bank. Boy was I wrong. Last week, in a Press Release, the Department of Justice (DOJ) announced a that Wells Fargo & Company and its...more
I am in the midst of a multi-part exploration of the Major League Baseball (MLB) investigation into allegations that the Houston Astros engaged in a multi-year scheme to steal signs and signals from opposing teams. MLB issued...more
The concept of institutional justice is basic to any compliance regime. Companies that seem to get into the most trouble are those that lack this basic concept. It means more than simply fair and equitable treatment; it...more
The General Motors (GM) 2018 Sustainability Report is out. It reports on GM’s progress toward an era of safer, better and more sustainable personal mobility by transforming how General Motors approaches every aspect of its...more
In the recently released Evaluation of Corporate Compliance Programs, 2019 Guidance by the Department of Justice, incentives are specifically identified in the section under “is your program effectively implemented?” The 2019...more
Many organizations struggle with their internal culture for a variety of reasons. Establishing a strong and compliant corporate culture is paramount for an effective compliance program, as even the DOJ has harped on in its...more
Never has the need for anti-corruption compliance programs for American companies been greater than it is today. This is not only for large multi-national companies, but for small to medium-sized businesses, particularly...more
You can be sure that, other than the inspirational underdog story of someone beating the odds or overcoming insurmountable obstacles, nothing garners more media attention than the fall of a prominent public figure. This is...more
A basic compliance program control, which is often overlooked (or assumed to exist), is the requirement that a chief compliance officer and/or chief legal officer have the authority to stop a specific contract or business...more
The government has emphasized the dangers of a paper compliance program, meaning a compliance program that is written down but not implemented. ...more
How does your organization support its ethics and corporate values required to support an integrity program? This is more than creating institutional justice and institutional fairness....more
This week on the Innovation in Compliance podcast, I interviewed Ellen Hunt, the Chief Audit Executive and Ethics & Compliance Officer at AARP. Hunt said the greatest impact executives can have on how they lead corporate...more
The Wells Fargo scandals continue to be one of the starkest lessons about the cost of a corrupt culture and the catastrophic effect it can have on an organization. The former Chief Executive Officer (CEO) and head of the...more
I have considered this in the context of third-parties, forecasting and the risk management process and through the use of a root cause analysis. Today, I want to conclude this week’s blog posts with a post on...more
I continue my exploration of how to change the culture in an organization based upon a series of articles in the most recent edition of the Harvard Business Review (HBR) by Boris Groysberg, Jeremiah Lee, Jesse Price and J....more
A lot of the focus on ISO 37001 so far has been on its value for companies considering certification as evidence of the quality of their own compliance program. With the SEC and DOJ both providing ample guidance to companies...more
Ok, ok, don’t panic. Maybe not all of the millions of dedicated readers of this blog are in violation. Nevertheless, as of June 1, if your company does business in France, it may be time to check your anticorruption...more
Today I continue my Code of Conduct exploration with Eric Morehead, Principal of Morehead Compliance Consulting. After having reviewed the legal requirement and business purpose in Part I, the structure and form of your Code...more
Last week I interviewed Susan Divers, Senior Advisor at LRN Corporation, on the company’s 2016 Ethics and Compliance Program Effectiveness Report (Report). The Report was a fascinating review of the evolution of compliance...more